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    <td class="contentHeader"><h2>Privacy policy of Swapen.com</h2></td>
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    <td class="content"><p>This policy tells you about how we use and protect your  personal information. </p>
      <p><strong>Contents</strong> </p>
      <ul type="disc">
        <li><a href="index.php?policy#Scope">Scope</a> </li>
        <li><a href="index.php?policy#Collection">Collection</a> </li>
        <li><a href="index.php?policy#Marketing">Marketing</a> </li>
        <li><a href="index.php?policy#Use">Use </a> </li>
        <li><a href="index.php?policy#Disclosure">Our Disclosure of Your Information </a> </li>
        <li><a href="index.php?policy#Activity">Information You Share on Swapen</a> </li>
        <li><a href="index.php?policy#Using">Using Information from Swapen </a> </li>
        <li><a href="index.php?policy#Cookies">Cookies</a> </li>
        <li><a href="index.php?policy#Spam">No Spam, Spyware or Spoofing</a> </li>
        <li><a href="index.php?policy#Protection">Account Protection</a> </li>
        <li><a href="index.php?policy#Accessing">Accessing, Reviewing and Changing Your Personal       Information</a> </li>
        <li><a href="index.php?policy#Security">Security</a> </li>
        <li><a href="index.php?policy#Third">Third Parties</a> </li>
        <li><a href="index.php?policy#General">General</a> </li>
      </ul>
      <p><a name="Scope" id="Scope"></a><strong>Scope</strong><br />
        This Privacy Policy describes how we handle your personal  information for our services on the Swapen websites. It applies generally to  the Swapen.com website and content and other related websites where this policy  appears in the footer of the page. Some Swapen-branded websites or websites we  operate may be governed by separate privacy policies. The policy that applies  on any of our domains or subdomains is always the policy that appears in the  footer of each website.<br />
        Our subsidiaries&rsquo; and joint  ventures&rsquo; privacy practices are similar to those described in this Privacy Policy.  Subject to the requirements of applicable law, we strive to provide a  consistent set of privacy practices throughout the global Swapen trading  community. By accepting the Privacy Policy and the User Agreement in  registration, you expressly consent to our collection, storage, use and  disclosure of your personal information as described in this Privacy Policy.  This Privacy Policy is effective upon acceptance for new users and is otherwise  effective on August 13, 2009. <br />
  <a name="Collection" id="Collection"></a><strong>Collection </strong><br />
        You can browse our sites without telling us who you are or  revealing any personal information about yourself. Once you give us your  personal information, you are not anonymous to us. If you choose to provide us  with personal information, you consent to the transfer and storage of that  information on our servers located in the United States. <br />
        We may collect and store the  following personal information: </p>
      <ul type="disc">
        <li>email address, physical contact information, and       (depending on the service used) sometimes financial information, such as       credit card or bank account numbers;</li>
        <li>transactional information based on your activities on       the sites (such as bidding, buying, selling, item and content you generate       or that relates to your account); </li>
        <li>shipping, billing and other information you provide to       purchase or ship an item; </li>
        <li>community discussions, chats, dispute resolution,       correspondence through our sites,&nbsp;and correspondence sent to us;</li>
        <li>other information from your interaction with our sites,       services, content and advertising, including computer and connection       information, statistics on page views, traffic to and from the sites, ad       data, IP address and standard web log information; </li>
        <li>additional information we ask you to submit to       authenticate yourself or if we believe you are violating site policies       (for example, we may ask you to send us an ID or bill to verify your       address, or to answer additional questions online to help verify your       identity or ownership of an item you list);</li>
        <li>information from other companies, such as demographic       and navigation data; and</li>
        <li>other supplemental information from third parties (for       example, if you incur a debt to Swapen, we will generally conduct a credit       check by obtaining additional information about you from a credit bureau,       as permitted by law).</li>
      </ul>
      <p><a name="Marketing" id="Marketing"></a><strong>Marketing </strong><br />
        We don't sell or rent your personal information to third  parties for their marketing purposes without your explicit consent. We may  combine your information with information we collect from other companies and  use it to improve and personalize our services, content and advertising. If you  don't wish to receive marketing communications from us or participate in our  ad-customization programs, simply indicate your preference in My Swapen or by  following the directions provided with the communication or advertisement. <br />
  <a name="Use" id="Use"></a><strong>Use </strong><br />
        Our primary purpose in collecting  personal information is to provide you with a safe, smooth, efficient, and  customized experience. You agree that we may use your personal information to: </p>
      <ul type="disc">
        <li>provide the services and customer support you request; </li>
        <li>resolve disputes, collect fees, and troubleshoot       problems; </li>
        <li>prevent potentially prohibited or illegal activities,       and enforce our User Agreement; </li>
        <li>customize, measure and improve our services, content       and advertising; </li>
        <li>tell you about our services and those of our corporate       family, targeted marketing, service updates, and promotional offers based       on your communication preferences; and </li>
        <li>compare information for accuracy, and verify it with       third parties.</li>
      </ul>
      <p><a name="Disclosure" id="Disclosure"></a><a name="Activity" id="Activity"></a><strong>Information You Share on Swapen</strong><br />
        Your User ID is displayed throughout Swapen (and so  available to the public), and is connected to all of your Swapen activity. Other  people can see your purchases, items for sale, storefronts, feedback, ratings  and associated comments. Notices sent to other community members about  suspicious activity and policy violations on our sites refer to User IDs and  specific items. So if you associate your name with your User ID, the people to  whom you have revealed your name will be able to personally identify your Swapen  activities. <br />
        If you access our sites from a  shared computer or a computer in an internet caf&eacute;, certain information about  you, such as your User ID, activity or reminders from Swapen, may also be  visible to other individuals who use the computer after you.<br />
  <a name="Using" id="Using"></a><strong>Using Information from Swapen </strong><br />
        Swapen enables you to share personal and financial  information to complete transactions. We encourage you to disclose your privacy  practices and respect the privacy of other users. We cannot guarantee the  privacy or security of your information and therefore we encourage you to  evaluate the privacy and security policies of your trading partner before  entering into a transaction and choosing to share your information. To help  protect your privacy, we allow only limited access to other users' contact,  shipping and financial information to facilitate your transactions. When users  are involved in a transaction, they <a href="#">may  have access</a> to each other's name, User ID,  email address and other contact and shipping information. In all cases, you  must give other users a chance to remove themselves from your database and a  chance to review what information you have collected about them.<br />
        You agree to use user information  only for:</p>
      <ul type="disc">
        <li>Swapen transaction-related purposes that are not       unsolicited commercial messages; </li>
        <li>using services offered through Swapen (<em>e.g.</em> escrow,       insurance, shipping and fraud complaints), or</li>
        <li>other purposes that a user expressly chooses. </li>
      </ul>
      <p><a name="Cookies"></a><strong>Cookies </strong></p>
      <p>We use &quot;cookies&quot; (small files placed on your hard  drive) on certain of our pages to help analyze our web page flow; customize our  services, content and advertising; measure promotional effectiveness, and  promote trust and safety. <br />
        A few important things you should  know about cookies are that: </p>
      <ul type="disc">
        <li>We offer certain features that are available       only&nbsp;through the use of cookies. </li>
        <li>We use cookies to help identify you and maintain your       signed-in status. </li>
        <li>Most cookies are &quot;session cookies,&quot; meaning       that they are automatically deleted from your hard drive at the end of a       session. </li>
        <li>You are always free to decline our cookies if your       browser permits, although doing so may interfere with your use of some of       our sites or services. </li>
        <li>You may encounter cookies from third parties on certain       pages of the sites that we do not control. (For example, if you view a web       page created by another user, there may be a cookie placed by that web       page.) </li>
      </ul>
      <p><a name="Spam" id="Spam"></a><strong>No Spam, Spyware or Spoofing</strong><br />
        We and our users do not tolerate spam. Make sure to set your  Swapen notification preferences so we communicate to you as you prefer. You are  not licensed to add other Swapen users, even a user who has purchased an item  from you, to your mailing list (email or physical mail) without their express  consent. To report Swapen-related spam or spoof emails to Swapen, please  forward the email to <a href="mailto:spam@swapen.com">spam@Swapen.com</a>. You may not use our communication tools to send spam or  otherwise send content that would violate our User Agreement. We automatically  scan and may manually filter messages to check for spam, viruses, phishing  attacks and other malicious activity or illegal or prohibited content, but we  do not permanently store messages sent through these tools. If you send an  email to an email address that is not registered in our community (via  Refer-a-Friend or other tools), we do not permanently store that email or use  that email address for any marketing purpose. We do not rent or sell these  email addresses. <br />
  <a name="Protection" id="Protection"></a><strong>Account Protection </strong><br />
        Your password is the key to your account. Use unique  numbers, letters and special characters, and do not disclose your Swapen  password to anyone. If you do share your password or your personal information  with others, remember that you are responsible for all actions taken in the  name of your account. If you lose control of your password, you may lose  substantial control over your personal information and may be subject to  legally binding actions taken on your behalf. Therefore, if your password has  been compromised for any reason, you should immediately notify Swapen and  change your password. <br />
  <a name="Accessing" id="Accessing"></a><strong>Accessing, Reviewing and Changing Your Personal Information </strong><br />
        You can see, review and change most of your personal  information by signing on to Swapen. Generally, we will not manually modify  your personal information because it is very difficult to verify your identity  remotely. You must promptly update your personal information if it changes or  is inaccurate. Once you make a public posting, you may not be able to change or  remove it. Upon your request, we will close your account and remove your  personal information from view as soon as reasonably possible, based on your  account activity and in accordance with applicable law. We do retain personal  information from closed accounts to comply with law, prevent fraud, collect any  fees owed, resolve disputes, troubleshoot problems, assist with any  investigations, enforce our <a href="#">Swapen  User Agreement</a>, and take other actions otherwise permitted by law.<br />
  <a name="Security" id="Security"></a><strong>Security </strong><br />
        Your information is stored on our servers located in the  United States. We treat data as an asset that must be protected and use lots of  tools (encryption, passwords, physical security, etc.) to protect your personal  information against unauthorized access and disclosure. However, as you  probably know, third parties may unlawfully intercept or access transmissions  or private communications, and other users may abuse or misuse your personal  information that they collect from the site. Therefore, although we work very hard  to protect your privacy, we do not promise, and you should not expect, that  your personal information or private communications will always remain private. <br />
  <a name="Third" id="Third"></a><strong>Third Parties</strong><br />
        Except as otherwise expressly included in this Privacy  Policy, this document addresses only the use and disclosure of information we  collect from you. If you disclose your information to others, whether they are  bidders, buyers or sellers on our sites or other sites throughout the internet,  different rules may apply to their use or disclosure of the information you  disclose to them. Swapen does not control the privacy policies of third  parties, and you are subject to the privacy policies of those third parties  where applicable. We encourage you to ask questions before you disclose your  personal information to others. <br />
  <a name="General" id="General"></a><strong>General </strong><br />
    We may amend this Privacy Policy at  any time by posting the amended terms on this site. All amended terms  automatically take effect 30 days after they are initially posted on the site.  In addition, we will notify you through the Swapen Message Center. If your  questions are not answered online, you may write to us at: Swapen Inc. using  the <a href="#">Contact Us</a> form.</p></td>
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